NARHC-News Updated FAQs on RHC Testing Fund Clarify Key Issues
Contributor: Nathan Baugh, National Association of Rural Health Clinics
https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questionsToday, HRSA released updated FAQs on the RHC testing fund (link above). I highly recommend that RHCs review the entire document but I wanted to highlight three of the FAQs for the community:
Are RHCs required to perform COVID testing onsite or can the testing occur at another facility?
RHCs should utilize this funding to best address the testing needs of their local communities, including administration of tests and/or laboratory services. RHCs may not have the ability to perform COVID testing onsite, or they may determine that testing may be carried out more effectively in another setting. Under such a scenario in which the testing is conducted offsite and/or by a third party, the RHC (identified by TIN) that received the funds must be actively involved in the administration and oversight of the testing program.
For example, the RHC may wish to conduct testing at an affiliated provider facility (e.g., hospital linked to the RHC) or in collaboration with other community entities such as a local employer, school, or other nearby providers. These and other partnerships are allowable. However, the organization represented by the RHC TIN must be able to report accurately and timely information to HHS as requested and demonstrate that it is actively managing the testing program. Further, the program requires that the physical testing site be reasonably situated in the same service area as the RHC to effectively serve the RHC’s patients.
How can RHCs determine if an expense meets the criteria of an allowable use of funds under the Rural Health Clinic Testing program?
This funding should assist RHCs in expanding the range of testing and testing-related activities to best address the needs of their local communities. This includes both direct costs of COVID-19 testing and other related expenses. Related expenses are described in the Terms and Conditions, and may include expenses related to building temporary structures, leasing, and retrofitting facilities; activities to support implementation of a COVID-19 testing program; or items and services furnished to an individual during health care visits.
In addition to ensuring that testing and related expenses fall within the bounds of the Terms and Conditions, the RHC must be able to demonstrate that the related expense is directly and reasonably related to the provision of COVID-19 testing services. The related expense must also be appropriate given relevant clinical and public health guidance. For example, the RHC may seek to retrofit the RHC facility to provide space for COVID-19 testing separated from the main clinic area for infection control purposes. However, a questionable use would be applying funds under this program to support a facility expansion planned prior to the COVID-19 pandemic. This may be allowable, but only if the RHC can demonstrate how it is using the expanded space to accommodate COVID-19 testing services in manner consistent with clinical/public health guidelines and community needs, and that other funds were not already obligated for this specific purpose.
How does insurance payment affect allowable uses of funding under the Rural Health Clinic Testing program?
RHCs under this program can provide testing for uninsured and insured patients, but per the Terms and Conditions may not use this payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Other sources of reimbursement include payments from insurance providers, Medicare or Medicaid, other Provider Relief Fund payments, and potentially other payers such as workers compensation insurance or employers. Entities providing testing under this program must seek reimbursement for services provided whenever other sources are obligated to reimburse the RHC for the testing or testing-related services, such as where patients have public or private insurance that covers their COVID-19 testing.
RHCs may use funds for the upfront purchase of supplies necessary to implement and operate a testing program, such as test kits, swabs, and PPE. Similarly, RHCs may use funds for other startup costs needed to implement a testing program including, but not limited to, retrofitting facilities or hiring staff to carry out COVID-19 testing. At this point, none of these expenses have yet been reimbursed by another source, nor is another source yet obligated to reimburse them.
But where another source of reimbursement, such as public or private insurance coverage, subsequently reimburses or becomes obligated to reimburse the RHC for COVID-19 testing and/or testing-related services, the RHC should ensure that these external payments are accounted for. For example, should the RHC recoup some of the costs of COVID-19 testing and/or testing related services through insurance reimbursements or other payments, the RHC should maintain a record of this, including the amount of RHC COVID-19 Testing money recouped, and ensure those RHC COVID-19 Testing funds are used to support other, unreimbursed COVID-19 testing and/or related expenses consistent with the Terms and Conditions.
Despite insurance coverage, not all testing-related activities may be reimbursable and RHCs may also apply funds towards these items and services. For instance, if there is no way for an RHC to receive reimbursement for a service because no allowable billing code exists, then RHCs may use funds towards this activity even for insured patients.
Contributor: Nathan Baugh, National Association of Rural Health Clinics
Reviving this old thread to inform folks that HRSA has published updated FAQs on the RHC COVID-19 Testing Program today. The updated FAQs clarify how RHCs may attribute costs to COVID-19 testing and testing related expenses. The FAQ also clarifies that reporting on RHCcovidreporting.com is expected to continue until July 31, 2021 although HRSA reserves the right to revise that date.
Make sure you review the new FAQs here and look for the "updated 2/21/2021" timestamp: https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questions
Contributor: Nagaratna Reddy, Reddy Family Medical Clinic Donaldsonville
Good Morning Medicare or Medicare advantage plans do not pay for us giving vaccine to patients-RHCs. Is there any incentives in the stimulus plan for RHCs for giving vaccines. We have given over 2500 vaccines so for and it is affecting our patient care for regular patients. Will you please check with NARHC regarding this if not we may have to stop giving vaccines as it is burdensome for the clinics Nagaratna Reddy ---------- Original Comments ---------- Last Post By: Nathan Baugh, National Association of Rural Health Clinics Reviving this old thread to inform folks that HRSA has published updated FAQs on the RHC COVID-19 Testing Program today. The updated FAQs clarify how RHCs may attribute costs to COVID-19 testing and testing related expenses. The FAQ also clarifies that reporting on RHCcovidreporting.com is expected to continue until July 31, 2021 although HRSA reserves the right to revise that date.
Make sure you review the new FAQs here and look for the "updated 2/21/2021" timestamp: https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questions
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